Chapter 1: General Provisions

Article 1 (Purpose)

The purpose of these regulations is to establish matters concerning the comprehensive management and appropriate disclosure of the company’s internal information to ensure prompt and accurate disclosure in accordance with relevant laws, and to prevent insider trading by executives and employees.

Article 2 (Definitions)

1. “Internal Information” refers to matters subject to disclosure under Chapter 1 of the KOSDAQ Market Disclosure Regulations (hereinafter referred to as the "Disclosure Regulations") and other information that may affect the company's management or financial condition, or influence investors’ decisions.
2. “Disclosure Officer” refers to a person authorized to report on behalf of the company in accordance with Article 2, Paragraph 4 of the Disclosure Regulations.
3. “Executive” refers to directors (including those as defined in Article 401-2, Paragraph 1 of the Commercial Act) and auditors.
4. Terms not defined in this Article shall follow the definitions in relevant laws and regulations.

Article 3 (Scope of Application)

Unless otherwise provided by relevant laws, regulations, or the Articles of Incorporation, matters concerning disclosure, insider trading, and internal information management shall follow these regulations.

Chapter 2: Management of Internal Information

Article 4 (Management of Internal Information)

1. Executives and employees must strictly manage internal information acquired in the course of their duties and must not leak it internally or externally, except when necessary for business.
2. The CEO or the Disclosure Officer must take necessary measures to manage internal information, such as setting detailed standards for storage, delivery, and disposal of documents and data related to internal information.

Article 5 (Disclosure Officer)

1. The CEO shall designate a Disclosure Officer and report this to the Korea Exchange (KRX). Any changes must also be reported.
2. The Disclosure Officer oversees the establishment and operation of the internal information management system and performs the following tasks:

3. The Disclosure Officer has the authority to:

4. The Disclosure Officer may consult with other executives or seek expert assistance at the company’s expense.
5. The Disclosure Officer must regularly report on the operation of the internal information management system to the CEO.

Article 6 (Disclosure Manager)

1. The CEO or Disclosure Officer shall designate a Disclosure Manager and report to the Korea Exchange. Any changes must also be reported.
2. The Disclosure Manager performs the following under the supervision of the Disclosure Officer:

Article 7 (Centralization of Internal Information)

Executives and department heads must report to the Disclosure Officer in the following cases:

Article 8 (Provision of Internal Information to External Parties)

1. If internal information must be provided externally for business purposes (e.g., to partners, external auditors, legal/management advisors), it must be reported to the Disclosure Officer.
2. The Disclosure Officer must take appropriate measures, such as confidentiality agreements.

Chapter 3: Disclosure of Internal Information

Article 9 (Types of Disclosure)

Disclosures are categorized as follows:

Article 10 (Execution of Disclosure)

1. When a disclosure matter arises, the Disclosure Manager shall prepare the necessary documents and report to the Disclosure Officer.
2. The Disclosure Officer shall review the documents for legal compliance, report to the CEO, and proceed with the disclosure.

Article 11 (Post-Disclosure Measures)

If any errors or omissions are found in the disclosed information, the Disclosure Officer and Disclosure Manager must take corrective measures immediately.

Article 12 (Press Inquiries)

1. Press inquiries shall be handled by the CEO or Disclosure Officer. Relevant executives or employees may be involved if necessary.
2. Press releases must be approved by the Disclosure Officer, who may report them to the CEO.
3. If media coverage is found to be inaccurate, the matter must be reported to the Disclosure Officer, who shall inform the CEO and take necessary action.

Article 13 (Investor Relations Presentation)

Any IR (Investor Relations) presentation regarding business performance or plans must be approved by the Disclosure Officer in advance.

Chapter 4: Regulation of Insider Trading

Article 14 (Return of Short-Swing Profits)

1. Executives and employees (who may have access to undisclosed material information) must return any profits made from trading specific securities within a 6-month period (buy then sell or sell then buy).
2. If a shareholder requests the company to reclaim such profits, the Disclosure Officer must take necessary action within two months.
3. Upon notification by the Financial Services Commission, the Disclosure Officer must publicly disclose:

4. This disclosure must be maintained for two years or until the profit is returned, whichever is earlier.

Article 15 (Notification of Securities Transactions)

Executives and employees must notify the Disclosure Officer of any transactions involving company securities.

Article 16 (Prohibition of Using Undisclosed Material Information)

Executives and employees are prohibited from using or allowing others to use undisclosed material information (including that of affiliates) for securities trading.

Chapter 5: Supplementary Provisions

Article 17 (Education)

The Disclosure Officer and Disclosure Manager must complete disclosure-related training, and the Disclosure Officer must ensure this knowledge is shared with relevant executives and employees.

Article 18 (Amendment and Repeal of Regulations)

These regulations may be amended or repealed by the CEO.

Article 19 (Publication of Regulations)

These regulations shall be published on the company website. The same applies when they are amended.

Addendum

These regulations shall come into effect on September 1, 2009.

M2N Co., Ltd.
CEO: Seung-Gun Lee
Business Registration Number: 135-81-05130